Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 18.3


Several types of documents, reports, and forms are used during the Hawai`i SCP release response process. In preparing documentation, several basic questions should be considered. For example, hazardous substance releases vary greatly in size, impact, and complexity, but the same essential questions are asked about every release and every response action:

  • What hazardous substance was released? Where did it go in the environment?
  • Did you look for the right things, in the right places, using the right methods?
  • Could the release pose an environmental hazard? What kind of environmental hazard, and under what circumstances?
  • What are the possible cleanup actions you could take to address these hazards?
  • What cleanup action did you choose to do? Why did you choose that action?
  • Was your cleanup successful? How did you measure your success? What was your cleanup objective, and did you meet it?
  • Did you leave any hazardous substances onsite after completion of the cleanup? If so, what and where are they, and what should be done about them?

The documentation of a response action should address all of these questions. The level of detail needed to do so will vary greatly depending on the specific circumstances of each hazardous substance release.

In emergency response removal actions, due to the urgent threats posed by these releases, there is little opportunity for formal review and consultation with other parties prior to decision-making. Many of these questions are addressed informally, often with pre-established decisions for specific scenarios, and simply documented after the fact (see Section 2.3).

In non-emergency environmental cleanups (site investigations, removal actions, or remedial actions), these questions should be addressed in detail. Reports should explain the objectives, methods, and results in enough detail to be clearly understandable by the HEER Office and provide adequate documentation and support for investigation and cleanup decisions. If reports are poorly documented, decisions cannot be supported by the HEER Office regardless of how appropriate and well-executed the investigation or response may have been.

The primary Hawai`i SCP reports and forms are listed below. Suggested outlines for each, as well as applicable forms, are presented in Subsection 18.5.

  • Release Notification Report
  • Site Prioritization Form*
  • Response Action Determination Form*
  • Removal Action Plan
  • Removal Action Report
  • Public Notice for Removal Action Report
  • Sampling and Analysis Plan (SAP)
  • Quality Assurance Project Plan (QAPP)
  • Site Investigation Report
  • Environmental Hazard Evaluation
  • Remedial Investigation Report
  • Remedial Alternatives Analysis (RAA) Report
  • Response Action Memorandum (RAM)*
  • Public Notice for Draft Response Action Memorandum
  • Remedial Action Work Plan
  • Remedial Action Report
  • Environmental Hazard Management Plan
  • "No Further Action" Letter*
  • "No Further Active Remediation" Letter*
  • Voluntary Response Program Letter of Completion*

* These forms, memoranda, or letters are the responsibility of the HEER Office to document official HEER Office decisions. However, they may be utilized by consultants/PRPs as planning tools.

Supporting Hawai`i SCP documents and forms include:

  • Soil Boring Log
  • Monitoring Well Installation Log
  • Monitoring Well Abandonment Form
  • Voluntary Response Program Application
  • Environmental Covenant
  • Removal or Remedial Action Fact sheets